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Credit Cards Disclosure Requirements

Stinson LLP

Changes to Virginia and Oklahoma Surcharge Laws

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As this year’s legislative session is wrapping up, two states, Virginia and Oklahoma, enacted legislation to reform their laws related to surcharges. May 2, 2025, Virginia Gov. Glenn Youngkin signed Senate Bill 1212 to amend...more

Holland & Knight LLP

CFPB Credit Card Late Fees Rule Vacated by Texas District Court

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On April 15, 2025, Judge Mark T. Pittman of the U.S. District Court for the Northern District of Texas entered an order and final judgment vacating the CFPB's credit card penalty fees rule (the Late Fee Rule). Judge Pittman's...more

Goodwin

Want to Have Customers Cover Payment Processing Fees? What You Need to Know About Credit Card Surcharging

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Credit card surcharging is on the rise. Imposing a surcharge in a compliant manner is more than adding a fee at the point of sale. Below we review on a high level the legal and commercial considerations for merchants before...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes CARD Act-mandated request for information

On January 17, the CFPB published in the Federal Register a Request for Information (RFI) about a number of aspects of the consumer credit card market, as mandated by the CARD Act. The RFI seeks public input to shape the...more

Holland & Hart LLP

Open Banking Rules are Finally Here: What's Next for the Financial Services Industry

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On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued its long-anticipated Open Banking Rule (the Open Banking Rule) under Section 1033 of the Dodd-Frank Act, fundamentally reshaping the data-sharing...more

Fenwick & West LLP

California’s Hidden Fee Ban: FAQs and Guidance

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On July 1, 2024, California’s law banning hidden fees took effect. Under the Consumer Legal Remedies Act (CLRA), SB 478 provides that businesses transacting with California consumers may not apply additional fees or charges...more

Ballard Spahr LLP

In Rare Move, the CFPB Comes to the Defense of Bank

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In an unusual move, the CFPB is coming to the defense of a bank being accused of failing to provide repayment disclosures to a borrower....more

Nutter McClennen & Fish LLP

Nutter Bank Report: March 2024

The SEC has issued a controversial 886-page final rule imposing climate-related disclosure requirements on publicly traded companies, including banking organizations, which will require them to include certain climate-related...more

Venable LLP

New York Implements a New Surcharge Law: What the Changes Mean for Shoppers and Businesses

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On February 11, 2024, a new law went into effect in New York, establishing important limits and rules for surcharging. Enacted in December 2023, the new statute has a price disclosure component, detailing how surcharge prices...more

Cozen O'Connor

Credit Card Surcharging Regulatory Changes Create Both Risks and Opportunities for Businesses

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Credit card surcharging has increasingly gained the attention of consumers, businesses, and regulators over the past few years, and for good reason. As inflation continues to squeeze businesses and consumers alike, many...more

Fox Rothschild LLP

NY State Mandates Disclosure of Credit Card Surcharges

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Under a new law that took effect on February 11, 2024, all “sellers” in New York who apply a credit card surcharge to sales transactions must now comply with certain consumer disclosure requirements. Signed into law by...more

Troutman Pepper Locke

New York Enacts Credit Card Surcharge Caps and Disclosure Requirements

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Last month, New York Governor Kathy Hochul signed into law Assembly Bill 2672, which both prohibits sellers from charging a credit card surcharge greater than what they are charged by the credit card company and requires...more

Ballard Spahr LLP

Atlantic Union Bank to pay $6.2M for its unlawful overdraft opt-in practices

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On December 7, 2023, Atlantic Union Bank (the “Bank”) entered into a consent order with the Consumer Financial Protections Bureau (CFPB) related to its in-person and telephone overdraft opt-in sales practices during...more

Barnea Jaffa Lande & Co.

Price Display in Credit Transactions: What are the Obligations?

The Haifa District Court recently handed down a ruling in a motion to certify a class action filed against Ofir Tours Ltd. by its customer. The plaintiff bought an Eilat hotel vacation through Ofir Tours, paying in credit...more

Hinch Newman LLP

Roundup of FTC Consumer Protection Matters of Interest to Digital Advertisers: April 2023

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In April 2023, the Federal Trade Commission announced a number of consumer protection actions and inquiries involving an important U.S. Supreme Court Ruling regarding the ability of defendants in FTC and SEC actions to raise...more

Goodwin

Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities

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Regulatory Developments - Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities - On February 23, the Federal Reserve, FDIC and OCC (the Agencies) issued a “Joint...more

Goodwin

CFPB Prepaid Accounts Rule Challenged in Lawsuit by PayPal

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On December 11, 2019, PayPal, Inc. (PayPal) filed suit against the Consumer Financial Protection Bureau (CFPB) in the District of Columbia, challenging the CFPB’s Prepaid Accounts Under the Electronic Fund Transfer Act...more

Ballard Spahr LLP

CFPB releases report on college credit card agreements

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The CFPB released its sixth annual report to Congress on college credit card agreements.  The annual report is mandated by the CARD Act. ...more

Ballard Spahr LLP

Fed issues consent order for bank’s alleged deceptive practices involving balance transfer credit cards

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The Federal Reserve Board announced that it had issued a Consent Order against Mid America Bank and Trust Company (Bank) for alleged deceptive marketing practices in violation of section 5 of the FTC Act related to balance...more

Morrison & Foerster LLP

Financial Services Report - Summer 2017

EDITOR’S NOTE - Summer blockbuster season is officially upon us. Have you seen Wonder Woman yet? What about Guardians of the Galaxy Part 2? It’s déjà vu all over again with Baywatch, Pirates of the Caribbean, Alien,...more

Morrison & Foerster LLP

CFPB Proposes Changes to Prepaid Accounts Rule

On June 15, 2017, the Consumer Financial Protection Bureau (“CFPB”) released proposed revisions to its final Prepaid Accounts Rule (“Final Rule”). The Final Rule was published in November 2016 and was subsequently amended to...more

Herbert Smith Freehills Kramer

Advertising Litigation Report: Vol. 2, No. 2 - Consumer Privacy and Data Security

Judge Trims Proposed Class Action Over Wendy’s Data Breach - Torres v. Wendy’s Int’l, LLC, No. 16-cv-0210 (PGB) (DCI) (M.D. Fla. Mar. 21, 2017). A U.S. district court judge in Florida trimmed a proposed class action...more

Seyfarth Shaw LLP

Supreme Court Says Credit Card Surcharge Ban Regulates Free Speech

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The Supreme Court in Expressions Hair Design et al. v. Schneiderman held that New York’s law prohibiting credit card surcharging (General Business Law §5 18) regulates speech, and on Wednesday asked the Second Circuit to...more

Stoel Rives LLP

Credit Card Surcharge Ban on Life Support after Supreme Court Decision

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The U.S. Supreme Court held last week that New York’s ban on credit card surcharging is a restraint on speech under the First Amendment. Expressions Hair Design v. Schneiderman, No. 15-1391 (U.S. Mar. 29, 2017). The case was...more

Snell & Wilmer

U.S. Supreme Court - Credit Card Disclosure Statute Regulates Free Speech

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In a unanimous decision, the U.S. Supreme Court recently held that retailers engage in protected speech when they communicate their prices to customers. Specifically, the Court addressed communication regarding differential...more

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